Business Restructuring

Are you considering restructuring or closing operations?

Transfer pricing is often not considered when changes are made to business operations. However, the CRA continues to focus on the compensation due to a Canadian entity where its business activities have been restructured. Related CRA proposals tend to be time consuming and costly to defend. Upfront planning and advice may help mitigate costly future CRA audits.

PwC can help you review and document the facts and circumstances surrounding your company’s decision to change its business operations in the context of the arm’s length principle. We also review the treatment of costs associated with the actual changes to operations and any associated transfers of intangibles or other assets.
 

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Marc Levstein

Marc Levstein

Partner, Value Chain Transformation (VCT) Leader, PwC Canada

Tel: +1 647 388 5692

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Dean Landry

Dean Landry

National Tax Leader, PwC Canada

Tel: +1 416 815 5090

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